ML20204F131

SALP Board Insp Repts 50-295/87-01 & 50-304/87-01 for Oct 1985 - Nov 1986.Category 1 Rating Given in New Functional Areas of Outages & Training & Qualification Effectiveness & Security & Licensing Activities

ML20204F131
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/16/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204F033	List: ML20204F027 ML20204F131
References
50-295-87-01, 50-295-87-1, 50-304-87-01, 50-304-87-1, NUDOCS 8703260140
Download: ML20204F131 (36)

See also: IR 05000295/1987001

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SALP 6

SALP BOARD REPORT

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

50-295/87001; 50-304/87001

Inspection Report No.

Commonwealth Edison Company

Name of Licensee

Zion Units 1 and 2

Name of Facility

October 1,1985 through November 30, 1986

Assessment Period

40 87

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TABLE OF CONTENTS

Page No.

I. INTRODUCTION 1

II. CRITERIA 2

III. SUMMARY OF RESULTS 4

IV. PERFORMANCE ANALYSIS 5

A. Plant Operations 5

B. Radiological Controis 8

C. Maintenance 11

D. Surveillance 13

E. Fire Protection 14

F. Emergency Preparedness 16

G. Security 17

H. Outages 19

I. Quality Programs and Administrative Controls 22

Affecting Quality

J. Licensing Activities. 24

K. Training and Qualification Effectiveness 26

V. SUPPORTING DATA AND SUMMARIES 29

A. Licensee Activities 29

B. Inspection Activities 30

C. Investigations and Allegations Review 31

D. Escalated Enforcement Actions 31

E. Licensee Conferences Held During Assessment Period 31

F. Confirmatory Action Letters 31

G. Review of Licensee Event Reports and 10 CFR 21 Reports 32

H. Licensing Actions 33

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I. INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

l integrated NRC staff effort to collect available observations and data on

( a periodic basis and to evaluate licensee performance based upon this

l information. SALP is supplemental to normal regulatory processes used to

j ensure compliance to NRC rules and regulations. SALP is intended to be

sufficiently diagnostic to provide a rational basis for allocating NRC

resources and to provide meaningful guidance to the licensee's management

to promote quality and safety of plant construction and operation.

An NRC SALP Board, composed of staff members listed below, met on

February 10, 1987, to review the collection of performance observations

and data to assess the licensee performance in accordance with the

guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee

Performance." A summary of the guidance and evaluation criteria is

provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety

performance at the Zion Generating Station for the period October 1,

1985, through November 30, 1986.

SALP Board for Zion Generating Station:

Chairman

• J. A. Hind, Director, Division of Radiological Safety and Safeguards

Board

• C. E. Norelius, Director, Division of Reactor Projects

• C. J. Paperiello, Director, Division of Reactor Safety

• J. A. Norris, Licensing Project Manager, NRR

• M. M. Holzmer, Senior Resident Inspector

R. F. Warnick, Chief, Projects Branch 1

• B. L. Burgess, Chief, Reactor Projects Section 2A

P. L. Eng, Resident Inspector

J. W. McCormick-Barger, Reactor Engineer, Technical Support Staff

R. M. Lerch, Project Inspector, Section IA

• Voting members of the Board.

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II. CRITERIA ~ [,c

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5 ThE licinsee s performance is a s ssed in selected functioNN areas '

dependird whether the facilith' inaconstruEtioQere-oMati'enalor ,.

operating phase. Each functienal aree normal 7y reprtcentsp an(area

significant to nuclear safety \nd che environment, and is a normal i

programmatic area, Soms functional areas aay not be,a'ssessed because of '

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little or no licensee activities or lack of mearingfdl observations.

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Special areas may be added to highlight significant observations. is

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One'or more of the following evdation crira-ia' were. used to assess each -

functt g 1 area.

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A. /y sManagement involvement in@ssuring qualf ty. .

Approachtoresolutionoftechnicalissuesfpmasafetystandpoint.\

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C. ' i desponsiveness to NRC init'.Ttives. 1 (

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D. Enfoicede.'t histor'y.

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E. )OperationalandConstructionevents(fnclydingresponseto,analhsis

of, and corrective,hgi,ols for). ,{ )

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F. Staffing (including *mana'gement). '

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However, the SALP Board is not limited,to thhe criteria and others may

have been used where appropriate.' g i.'

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BasedupontheSALPBoa'rdasse'ssmnt,babifunctionalareae'vafuatedis . .

classified into one of three performance \ sate @. ies. The definftfon of ds

these performance categories is: g

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Category 1: Reduced NRC attention may be apropriate. Licensee h

management attention and involvement ar2 aggressive and oriented toward (

nuclear safe'ty; licensee resources are ample and effectivWy used so that

a high level of performance'with respect to operational satAty or 4

monstruction is being achhved. '

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Category 2: NRCattentionkhouldbemaintainedatnormallevels.

Licensee management attention and involvement are evident and are

concerned with nuclear safety; licensee resources are adeduate and are g

reasonably effective such that satisfactory performance with '

respect to '

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operatipnal safety or constrb: tion is being achieved.

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Catejoay 3: Both NRC and licensee attention should be Ocreased.

Licensee management attentKr or involvement is acceptable and considers (

nuclear safety, but weaknesses are evident; licensee resources appear to i '

be strained or not effectively used so that minimally satisfactory s

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performance with respect to operational safety or construction is being '

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Trend: The SALP Board may determine to include an appraisal of the

performance trend of a functional area. Normally, this performance

trend is only used where both a definite trend of performance is

discernible to the Board and the Board believes that continuation of  ;

, the trend may result in a change of performance level.

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J'.. The trend, if used, is defined as:

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a. Improving

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Licensee performance was determined to be improving near the close '

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of the assessment period,

b. Declining

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Licensee performance was determined to be declining near the close

of the assessment period.

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III. SUMMARY OF RESULTS s

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/ '0verall, the NRC has found the licensee's performance' acceptable and -

'dir'ected toward safe facility operation. However,ithe Ticensee's 1 <

overall performance remained lat the same . level identifie'd in the last

SALP period. A Category 1 rating was given in the new functional areas

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of Outages and Training and Qualification Effectiveness. Continued e

Category 1 performance was noted in the areas of Security and Licensing

Activities and seven areas remained at a Category 2 rating. The licensee i

should continue to provide aggressive management attention to the SALP

Category 2 functional areas -in order to achieve the level of performance

desired by both the NRC and the licensee. '

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, Ratfag Rating Thisp

Functional' Area i SALP :5 / Period

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Trend

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A. Plant Operations '

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B. Radiological Controls 2 2

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. Emergency Preparedness

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G. Security 1 1 1

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K. Training and Qualification

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• • Not rated (new( functional area for SALP 6)

< For SALP 6.the previous Refueling functional area has been expanded to

encompass al' major outage activities.

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IV. PERFORMANCE ANALYSIS

A. Plant Operations

1. Analysis

During the assessment period, nine inspections were performed

by the resident inspectors in this functional area. This

assessment was based on direct observation of operating

activities such as startups, shutdowns, routine evolutions and

response to abnormal plant conditions, reviews of logs and

other records, verification of equipment lineup and

operability, and followup on significant cperating events.

Five violations of NRC requirements were identified in this

area during the assessment period, all of which were Severity

Level IV. One of the violations stemming from an auxiliary

feedwater pump being inoperable for 14 days longer than allowed

by Technical Specifications (TS), resulted in an enforcement

conference and a proposed Severity Level III violation. Appeal

of the severity level by the licensee was found acceptable by

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the NRC and the violation was issued as a Severity Level IV

on December 19, 1986. Another violation, consisting of failure

to meet TS requirements. involved the loss of recirculation

flow to the Unit 1 borce .njection tank (BIT) for a time period

in excess of that allowed by the TS.

Three other Level IV violations identified were failures to

meet the requirements of 10 CFR Part 50. One violation

involved the failure to report the closure of containment

purge valves as required by Part 50.72, and occurred early

in the assessment period. Since that time, the licensee has

adhered to the require.ments of both Parts 50.72 and 50.73.

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, Two other violations pertained to 10 CFR Part 50 Appendix B,

Criterion V, one of which resulted from the failure to follow

a procedural caution while attempting to pull fuses to main

steam isolation valve (MSIV) control power. The other, which

was the result of a procedural inadequacy as supported by

three examples, involved the loss of both trains the residual

heat removal system while the reactor coolant system was

partially drained for maintenance.

During the 17 month SALP 5 assessment period, there were six

violations of NRC requirements consisting of eight examples.

Compared with the current SALP period of 14 months and the

cited five violations consisting of seven examples, the rate

at which violations occur appears to be nearly equal. However,

two violations were related to events that represented a

greater safety significance than those that were noted during

the previous assessment period. These were the inadequacy

of Procedure MI-6 and the inoperability of the auxiliary

feedwater pump for 14 days longer than allowed by TS.

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Unit I tripped three times and Unit 2 tripped four times

during this assessment period, with six of the seven trips

occurring while the units were above 15% power and one of

the Unit 1 trips occurring between 0% and 15% power. All

reactor trips were automatic and not manual. Three of the

reactor trips were caused by equipment failures. Of these,

one was related to the turbine electro-hydraulic control

system, one was related to electrical noise in nuclear

instrumentation cabinets during surveillance testing, and one

was caused by instrument drift in a reactor protection system

bistable. Three trips were caused by personnel error or

training deficiency. Two of those were caused by instrument

mechanics and one was caused by a non-licensed operator. The

remaining reactor trip was caused by a lightning strike.

Reactor trips occurred at essentially the same rate as SALP 5,

with similar rates for root cause of personnel error and

equipment failures. There were also two trip signals at 0%

power, one for Unit I and one for Unit 2.

There were 24 Engineered Safety Feature (ESF) actuations during

this assessment period (excluding the reactor trip signals

discussed above). Five of these ESF actuations were due to

containment purge isolation signals, five were actuations of

one or more containment isolation valves, and four were

automatic starts of penetration pressurization air compressors.

In addition, six ESF actuations resulted from test activities,

and were caused by switch malfunctions, operator errors, and

procedural deficiencies. The licensee has complied with the

requirements of 10 CFR 50.72, and has reported conservatively

throughout the period.

Of 24 licensee event reports (LERs) which involved the

operations area, six involved inadequate procedures. The

remainder were evenly split between procedural violations,

technical knowledge deficiencies, communications errors, and

personnel errors.

The licensee routinely exhibited a conservative approach to

safety issues as indicated by their response to the four

unusual events which occurred during the assessment period.

In these cases, operating mode reductions were initiated or

made according to the technical situation, at the expense of

production. In addition, reactor startups following trips

were properly delayed until the licensee had completed a

determination of root cause of reactor trips, actions to

prevent recurrence, and correction of equipment problems.

For example, following the reactor trip that was caused by

a lightning strike, extensive testing was performed to

determine which electrical components had been affected by

the lightning.

Operator response to plant transients and events was generally

good. Detection of subtle changes in plant parameters led to

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the discovery of the failure of the 1B main steam check valve.

In addition, a leaky valve in the Unit 1 pressurizer spray line

was promptly detected by a radwaste operator who had observed

an increase in the frequency of cycles of the containment sump

pump. Several startups and shutdowns were observed by the

resident inspectors. During these evolutions, procedural

adherence, supervision, communications, and operator vigilance

were very good.

Control room behavior and conduct are addressed in detail in

corporate and plant directives and procedures, which

specifically prohibit sleeping, chronic lack of attentiveness,

alcohol or drug use, practical jokes, and other distractions

under penalty of disciplinary action including discharge. In

addition, radios, televisions, and non professional reading

materials are prohibited. Operator adherence to these

procedures is excellent. Operator's knowledge and awareness

of plant status is also very good. Operating units routinely

run with few alarm status lights. During the assessment period,

there were long periods in which fewer than four alarms were

illuminated for operating units. Plant management has also

acted to minimize the amount of traffic and reduce the number

of unnecessary personnel in the control room.

Several management positions changed in September of 1985,

including the Operating Assistant Superintendent, and Operating

Engineers. Since that time, management turnover has stabilized

with the exception of Shift Control Room Engineers (SCRE). Of

9 SCREs, only 2 have been in that position for more than 18

months. While no specific problems were identified, which

were attributed to the low level of SCRE experience, this is

considered an area of potential weakness.

The operations department has initiated several actions to

improve regulatory performance during the assessment period.

These include enhancements to control room professionalism and

appearance. One such action will be the remodeling of the

control room center desk area in 1987, which should provide a

better facility for shift management and control of access.

The licensee also initiated a procedure improvement program.

Aspects of this effort include contracted assistance to reduce

the backlog of procedure changes needed for the near term, and

contracted procedure development and revision assistance to

incorporate human factors principles and INPO guidelines into

all operating procedures. Operator involvement is also planned

to ensure that procedures are " workable". Conduct of opera-

tions improvements have included improved turnover, night

order, and standing order procedures. Reviews are also planned

for operator logs, the locked valve control program, and the

conduct of operations policy. Plant labelling improvements

have been in progress throughout the assessment period to

ensure that valve and component labels are properly provided.

A color coding scheme for the plant is also planned.

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2. Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rating of Category 2 in the last assessment period.

3. Board Recommendations

None

B. Radiological Controls

1. Analysis

Six inspections were performed during this assessment period by

region based inspectors. The resident inspectors also reviewed

portions of this area during routine inspections.

One Severity Level IV violation was identified concerning

failure to collect a reactor coolant sample for iodine analysis

within the required time frame.

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The licensee's management involvement has generally been good

with some exceptions. Audits are thorough and timely with

good responsiveness to findings. The licensee's efforts to

! improve worker adherence to station radiation protection

procedures by increased identification of offenders and

stronger disciplinary actions have been somewhat successful,

although further effort is necessary based on NRC inspector

observation of workers failing to properly frisk themselves

when leaving contaminated areas. Positive management control

initiatives during this assessment period include the formation

of a dry active waste (DAW) volume reduction committee,

periodic meetings between the Radiation Protection Manager

(RPM) and appropriate plant management, the auxiliary building

cubicle contamination reduction program, a corporate directed

secondary water chemistry control program, and various trending

programs. Several items, however, failed to receive timely

and thorough licensee management attention, including

development of compliance documentation for certain TMI

Action Plan Items, resolution of the acceptability of the

1983 modification and repair of the control room emergency

air cleaning system, and laundry operational problems. The

September 11, 1986, incident involving the inadvertent

intrusion of radioactive noble gas into the technical support

center (TSC) and control room gas control envelopes also does

not appear to have received appropriate management attention.

The licensee did not recognize until late November that the

TSC ventilation system apparently could not meet its design

objective. A comprehensive program to investigate the

technical and regulatory ramifications of the September 11,

1986, incident was not initiated until mid-December.

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Licensee staffing performance during this assessment period

has improved in some aspects and declined in others. The

radiation / chemistry technician (RCT) staff has stabilized with

a very low turnover rate; however, the turnover rate for the

professional health physics staff has been high resulting in

60% of the positions either vacant or filled with personnel

who have very little operating plant experience. The staffing

levels appear adequate, however, to perform the necessary

work activities in this functional area. A persistent problem

continues to exist in that the rotation of the RCTs between

health physics and chemistry groups results in long periods

of absence from the laboratory, which is conducive to a loss

of laboratory proficiency, especially in the use of

sophisticated analytical instrumentation.

Licensee responses to NRC initiatives have generally been

adequate. Improvements were made in response to NRC identified

weaknesses concerning radiological environmental monitoring

program (REMP) management, liquid effluent alpha counting,

degraded auxiliary building HVAC exhaust ductwork, in-situ

calibration of containment high range radiation monitors, and

management of 10 CFR 61 implementation. NRC concerns about

inconsistencies between the REMP and the Offsite Dose

Calculation Manual that carried over from the previous

assessment period were largely resolved with implementation of

the new Radiological Effluent Technical Specifications (RETS)

in the fall of 1986. Although, as stated above, certain TMI

Action Plan Items have remained unresolved for an extended

period, significant progress regarding compliance documentation

was made by the licensee near the end of the assessment period.

The licensee's approach to resolution of radiological technical

issues has generally been technically sound, thorough, and

timely. The licensee has realized significant dose savings by

establishing and diligently maintaining an effective ALARA

program. The 1985 personnel exposures were about 550

person-rems per reactor which is about 20% less than the

licensee's average over the previous five years but 35%

higher than the 1985 average for U.S. pressurized water

reactors. The 1985 personnel exposure level was due mostly

to extensive outage work on both units. The 1986 personnel

exposures are expected to total approximately 250 person-rems

per reactor. Noteworthy improvements implemented during this

assessment period include the continual reduction of the

contaminated floor area in the auxiliary building general

access area, initiation of the cubicle contamination reduction

program, and installation of new state-of-the-art whole body

frisking units. Problems identified during this assessment

period include lack of finalization of procedures and plans

for the use of the interim radwaste storage facility,

correction of certain HVAC system design deficiencies, problems

with implementation of dry active waste (DAW) compaction area

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facility modifications, lack of procedures for segregation of

" clean" DAW trash, and repetitive failures to meet technical

specification monitor surveillance requirements.

Radioactive gaseous effluents have remained about the same as

the previous period, about 2000 curies annually per unit,

reflecting the absence of any significant fuel cladding

problems and only minor primary to secondary leakage. Two,

minor, unplanned but monitored, gas releases resulted from a

leaky valve and a faulty computer chip related to a gas

analyzer associated with the water gas compressor. Appropriate

and timely measures were taken to preclude further releases

from these sources. Liquid effluents continued a generally

decreasing trend which began about five years ago. About 2

curies were released in liquid effluents in 1985 and about

0.7 curies were released during the first half of 1986. The

licensee continues to pursue an aggressive and effective solid

radwaste reduction program; solid radwaste generated in 1986

is expected to be about one-half and one-third that generated

in 1985 and 1984, respectively. No licensee radwaste trans-

portation problems were identified during this assessment

period.

Improvements in control of water quality were noted beginning

in the second half of 1985. Trend plots of key chemistry

variables showed that the plant was able to remain within

administrative limits about 99% of the time. The licensee has

adequate sampling capability on both the primary and secondary

systems, but plans to improve on-line monitoring of chemistry

variables in 1987.

Laboratory QA/QC was considerably improved with better use

of control charts for instrument performance data, testing

of technician performance with blind duplicate samples, and

participation in interlaboratory crosscheck programs for

radiological analyses. The station has had problems in

analyzing EPA environmental level radiological samples.

This comparison program will be replaced by vendor supplied

unknowns at concentrations more appropriate for station

analyses. The station achieved 55 agreements in 60

comparisons in the NRC confirmatory measurements program,

a slight decline in performance from the previous assessment

period. The licensee is taking appropriate corrective steps

including recalibration of gas geometries and analyses of a

spiked sample from the NRC reference laboratory.

2. Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rating of Category 2 in the last assessment period.

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3. Board Recommendations

None

C. Maintenance

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1. Analysis

During the assessment period, eight inspections were performed

by the resident inspectors in this functional area. This

assessment was based on direct observation of plant modifica-

tions, replacements, repairs, equipment overhauls, preventative

maintenance, maintenance organization and administration, and

response to events related to maintenance.

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Two Severity Level IV violations were identified in this area.

One violation resulted when the level in the containment spray

additive (Na0H) tank fell below the minimum required because

calibration procedures did not contain appropriate acceptance

criteria. Procedure revisions corrected the problem. The

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other. violation was cited for two examples where plant workers

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manipulated plant equipment without procedures and thereby

defeated the system design. In one case this resulted in a

reactor trip when a turbine pressure transmitter was isolated.

Eight violations were identified during the previous assessment

period, most of which were related to Instrument Mechanic

3 (IM) or Mechanical Maintenance (MM) procedures or procedure

i adherence. Revisions to all safety related IM pincedures,

begun during the previous assessment period, were completed

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and incorporated more detailed work instructions, cautions,

and independent verifications of return-to-service valve and

switch lineups. These revisions, combined with improved IM

performance have significantly reduced the number of IM related

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events.

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Of 34 LERs related to maintenance activities, 18 were caused

by equipment failures and 7 were caused by personnel errors.

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The remainder were due to instrument drift (4), installation

not meeting the design (3), and inadequate procedures or

design (2 each).

About 25 new MM procedures were written during the assessment

period, although this effort has been done on a spare time

basis. Late in the assessment period, a contract was prepared

to provide assistance in writing and revising MM procedures.

The need for improved MM procedures was highlighted in

October 1986, when the IB diesel generator (DG) threw a piston

connecting rod through the crankcase wall during a post

j maintenance run. The maintenance performed involved removal

, of the affected piston and cylinder liner. The procedure used

i was inadequate to prevent improper tcrquing of the connecting

i rod lower bolts, and the DG failure resulted.

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Maintenance staffing levels are generally adequate, however,

additional personnel appear needed to provide planning and

coordination of work activities, and to write procedures and l

work packages. Also, new demands on staff time for performing

more detailed work instructions and requalification training l

may impact the staff's ability to keep pace with work request.

Maintenance personnel, including management, are well trained

and adherence to procedures is generally good.

The backlog of maintenance work requests has varied depending

upon whether an outage is in progress, but was generally large

during the assessment period. This backlog, which includes

safety related and nonsafety-related modification and

preventive maintenance work requests, peaked at about 3250.

Equipment availability for safety related equipment was very

good, as indicated by relatively few entries into the Technical

Specifications (TS) limiting conditions for operation (LCO)

involving plant shutdown. Resolution of equipment operability

issues was typically handled on a technical basis, and

resolution involved appropriate consideration for safety.

Examples included repairs to plant equipment following the

July 1986, reactor trip due to lightning and the actions

taken following the failure of the 18 main steam check valve.

Equipment availability for some non-safety related plant

systems needs considerable improvement. Examples include

radiation monitors and recorders (including SPINGS, which are

the particulate / iodine / noble gas monitors), and instrument

air compressors. About half of the maintenance related LERs

reviewed involved equipment failures as causes or contributors

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to the events.

A formal preventive maintenance program still does not exist;

! however, many preventive maintenance activities do take place.

These include the development of an extensive vibration

monitort,a program, the use of oil samples to determine the

l need for bearing replacement, and inspections and rebuilding

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of many plant components including safety valves, snubbers,

ISI hangers, circuit breakers, and environmentally qualified

(EQ) components. Positive effects of these activities are

exhibited by the few shutdowns / reactor trips due to equipment

failures.

2. Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rating of Category 2 in the last assessment period.

3. Board Recommendations

None

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D. Surveillance

1. Analysis

During the assessment period, eight inspections were performed

by the resident inspectors in this functional area. This

assessment was based on direct observation of surveillance

activities, and review of surveillance procedures and

surveillance scheduling. Examination of this functional

area also consisted of three inspections by regional based

inspectors to examine activities as they relate to snubber

inservice inspection and the resolution of unresolved items

and IE Bulletins.

One event resulted in two Severity Level IV violations

during the assessment period. In this event, a control

room ventilation system HEPA filter was replaced without

the post-installation efficiency testing as required by the

Technical Specifications. Appropriate corrective actions

i

were implemented.

Management of surveillances improved during the period.

LER data indicate that 7 missed surveillances occurred

during the assessment period (14 months) compared to 15

during SALP 5 (17 months). In addition, 6 of 24 ESF

actuations occurred during surveillance testing. Two of

these were caused by personnel error, 2 by procedure

deficiency, and 2 by component failures during tests.

In response to NRC concerns expressed in SALP 5, the licensee

developed an action plan to reduce the number of missed

non periodic surveillances. These actions included:

-

Establishment of a master surveillance plan which would

computerize routine surveillances (monthly or less

frequent). This action is not yet complete.

-

Development of an "Off-normal / Transient Surveillance

Manual" (ZAP 10-52-1A, effective December 23, 1986) as

a guide to operators when changing mode or reactor power,

or when information is needed to supplement the Technical

Specifications.

Two examples of missed surveillances occurred following

implementation of the Radiological Environmental Technical

Specifications (RETS) on September 24, 1986. The RETS involved

numerous changes to surveillances on plant radiological

instrumentation and to sampling requirements. The licensed

received the RETS approximately 6 months prior to the

September 24 implementation date to provide adequate time

for review and development of necessary procedure changes.

Oversights during the review process resulted in missed

13

.

.. _ _ _ _ _ _ __ _

_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

.

. ..

surveillances on the TSC portable area monitor discovered

October 5, 1986, and in failure to take containment iodine

samples shiftly during Unit 2 containment vents on October 7,

1986.

Surveillance procedures reviewed during the period were

generally adequate, and technically correct. Individuals

performing surveillances adhered to procedures. At the end

of the assessment period, the licensee contracted for a

major rewrite of operating procedures which was to include

performance tests. This action should provide improved

uniformity in format, and incorporate INPO procedure guidelines.

The inspectors determined that snubber inservice inspection

records were generally complete, well maintained and

available. The licensee's responsiveness to the IE Bulletins

was timely, viable, and generally sound and thorough.

2. Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rating of Category 2 during the last SALP period.

3. Board Recommendations

None

E. Fire Protection

1. Analysis

Fire protection activities were observed during routine

resident inspections, and during followup of liceasee event

reports (LERS).

l

l One Severity Level IV violation was issued involving

'

inattentive fire watches.

Fourteen LERs were issued regarding fire protection. Eleven

of these were for inoperable or degraded fire barriers and

dampers. Some of the degraded barriers were identified during

quality assurance audits. Several of the inoperable dampers

were the result of inadequate knowledge of the damper design,

which rendered the dampers inoperable when the dampers were

removed from service for maintenance. The number of LERs

involving fire protection is considered too high and warrants

increased management attention.

Management attention to the posting of fire watches needed

improvement. In addition to the violation mentioned above,

there were two instances of fire watches required by Technical

Specifications that were not properly posted. One watch was

14

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_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

secured too early, and another was not posted for two hoa-s

due to a scheduling oversight. Interviews with fire watetes

also indicated the need for better directions and more specific

delineation of the requirements of the watch.

The fire protection staff consists of a Unit 1 operating

engineer assigned responsibility for implementing the fire

protection program, a Fire Marshal, and an additional

operations person assigned to do fire protection surveillances

under the direction of the Fire Marshal. Staffing is generally

adequate with weaknesses as evidenced by the fire damper and

fire watch reportable events.

Fire brigade training and the qualifications of fire brigade

members were good.

As reported in SALP 5, the licensee continues to be in

violation of the scheduler requirements of 10 CFR 50, Appendix

R, regarding fire protection modifications. During SALP 6,

the licensee resubmitted their plan to comply with Appendix

R. The licensee's plan is currently under review by NRR.

Housekeeping improved dramatically over the assessment period.

The auxiliary and fuel building walls were painted, and decks

were repainted. Tools and materials (such as scaffolding

materials and ladders) were inventoried and placed in dedicated

storage areas. Goals for outage and non-outage contaminated

areas were lowered, and the licensee plans to decontaminate

auxiliary building pump cubicles and release them for general

access. Leaks in the auxiliary building were generally

controlled, although some chronic service water leaks still

per.tst.

Painting in the turbine building was in progress by the end of

the assessment period. Painting included components, such as

turbines, pumps and valves, as well as walls, and general

areas. Tb? painting also included switchgear rooms and will

include diesel generators (DG) and DG rooms.

The units will be color coded, as will be certain process

pipes. Felt tip marker component labelling is being replaced

with engraved gravel ply labels. Metal valve identification

tags are also being added or replaced.

Housekeeping improvements have had a high management pricrity

during the assessment period, and as indiceted by the station

goals, this will continue into 1987.

2. Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rating of Category 2 in the last assessment period.

15

_ _ _ - _ _ _ _ _ _ _ _

.

.

3. Board Recommendations

None

F. Emergency Preparedness

1. Analysis

Two inspections were conducted during the period. These

included the observation of the unannounced, 1986 emergency

preparedness exercise and a routine inspection.

Management involvement and control in assuring quality has

generally been adequate. Independent audits of the program

were adequate in scope, depth, and frequency. Four

surveillances were conducted during the twelve month period

ending in March 1986, which is a greater number than required

by departmental instructions. Surveillance topics included

the annual exercise, a drill, and the licensee's response to

an actual emergency plan activation. However, the auditor

findings regarding the exercise and drill exhibited a lack

of emergency preparedness expertise when compared to the

findings of the licensee's specialists who also observed

those activities. Records of all quality assurance audits

and surveillances were complete and readily available, as

were records of emergency supplies inventories. However,

there were inadequate provisions for promptly replenishing

missing or depleted items identified during these periodic

inventories.

Between July 1985 and March 1986, the licensee activated the

emergency plan on four occasions. All situations were

properly classified. Required offsite notifications were

completed in an acceptable manner. While the station's

emergency planning coordinator independently evaluated the

records associated with each event, these evaluations varied

in quality and did not always identify problems later

identified by the inspectors. In contrast, the coordinator

j

'

maintained adequately detailed records of emergency prepared-

ness drills, including any corrective actions taken.

The licensee's responsiveness to NRC concerns has generally

been acceptable and timely. A notable long-standing

regulatory issue attributable to the licensee has been a

major revision to the Station's Emergency Action Levels

(EALs). The licensee's corrective action approach, was sound

and thorough. However, several time extensions were granted

before the revised EALs were finally submitted for staff

review.

As evidenced by walkthroughs and player performances during

the exercise, the licensee has maintained an adequate training

program for members of the onsite emergency organization.

16

_ -- . _ _ _ _ _ _ _ _ .

O

'

4

However, Training Department staff were unable to produce

documentation that all director-level personnel had been

trained during 1985 on all relevant emergency plan implementing

procedures in addition to the standardized training modules.

Although simulator training had supposedly included emergency

preparedness decisionmaking, no formal records of this aspect

of emergency preparedness training were maintained. The

licensee has committed to resolve both training documentation

omissions.

The licensee has maintained a prioritized roster of qualified

personnel to fill well-defined, key positions in the onsite

emergency organization. The licensee has demonstrated the

capability of augmenting onshift personnel in a timely manner

by conducting semiannual off-hours drills.

Corporate emergency planning staff has interfaced with the

station on the annual exercise, certain drills, and on

revisions to the emergency plan. Corporate staff has taken

the lead role in frequently interfacing with State and Federal

agencies in the ongoing major planning effort associated

with the 1987 Full Field Exercise. During 1986, corporate

management and staff were responsive to a Kenosha County

official's concern regarding issuance of potassium iodide

to the general public. The licensee met with State and local

officials to resolve the concern. The licensee also adequately

interfaced with Illinois State and local officials in resolving

the concerns of the owner of an Emergency Broadcast Station.

2. Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rating of Category 2 in the last assessment period.

3. Board Recommendations

None

G. Security

1. Analysis

Three security inspections (two routine and one special) were

conducted by regional inspectors during the assessment period.

Reduced inspection effort was the result of the licensee

being rated a Category 1 during the SALP 5 period. Two

allegations were received at the beginning of the period.

The allegations involved personnel access control and security

force performance issues and were determined to be unfounded.

One Severity Level IV violation was identified during the

assessment period. It involved a degradation of a vital area

barrier that did not, however, result in an easily exploited

17

.

.

access path. The licensee took prompt and extensive corrective

action which led to the immediate identification and correction

of an identical second breach. The events were reported within

the required time frame. The expeditious manner in which the

barrier degradation was analyzed and corrected was indicative

of an effective security program.

Licensee management's role in assuring quality was clearly

evident as demonstrated in the following examples. The shore

protection project which should prevent future damage to the

Protected Area (PA) intrusion detection system, involved a

concerted effort among the licensee's corporate security

director, the plant manager and the site security adminis-

trator. Considerable management effort was expended in

researching, planning and designing an appropriate solution.

The licensee's PA intrusion detection system continues to be

one of the more effective systems within Region III.

Additionally, the transition from one site security force

contractor to another during the period was smooth and without

impediments. The transition was clearly indicative of prior

planning.

With one exception, technical security issues were resolved

in a timely manner. The licensee's actions implemented as a

result of the identified Vital Area breach were the result

of a conservative approach in the analysis of the event's

significance. The corrective action taken was expeditious,

technically sound, and very thorough. There was only one

issue that was not resolved in the licensee's usually

consistent manner. Compensatory measures for a failed closed

circuit television camera observing the PA perimeter were not

addressed with a conservative approach; however, the licensee

does satisfy applicable security plan commitments.

Events reported in accordance with 10 CFR 73.71 were properly

identified and analyzed and were reported in a timely manner.

Timely and accurate reporting demonstrated excellent knowledge

of regulatory requirements and security commitments on the

part of the security force and also a comprehensive reporting

policy and comprehensive procedures.

The licensee has identified positions within the security

organization which are well defined and which possess the

appropriate level of responsibility. Key positions are filled

on a priority basis. The recent change of the site security

force contractor demonstrated the licensee's ability to

maintain a high level of performance during transition,

highlighting its dedication to a quality program.

During the most recent inspection, the NRC noted that some

central alarm station and secondary alarm station (CAS/SAS)

operators are sometimes required to work 16-hour shifts because

18

.

O

O i

their relief was not available. Some of the forced overtime

was caused by the unanticipated departure of two supervisory

personnel. The licensee was aware of the problem and had

initiated a cross-training program to ensure that qualified

personnel are available on each shift to perform CAS/SAS duties

in the event of an operator's unplanned absence. The initiative

should significantly reduce the frequency of 16-hour shifts by

CAS/SAS operators.

The training and qualification program is effective. Although

the program was not directly reviewed during the assessment

period, the lack of any significant security force personnel

errors and the sustained superior security force performance

were demonstrative of an effective training program. Training

inadequacies were not identified as the root cause of any

security event and, when questioned, security force personnel

were knowledgeable of security plan commitments and security

procedures.

During the assessment period, the morale of the security

force improved notably due, in part, to licensee management

initiatives to improve communications within the security

organization. Improved morale represents another enhancement

to a quality security program.

2. Conclusion

The licensee is rated Category 1 in this area. The licensee

received a rating of Category 1 in the last assessment period.

3. Board Recommendations

None

H. Outages

1. Analysis

Examination of this functional area consisted of routine

observations by resident inspectors during LER followup and

attendance at station meetings, as well as inspections by

regional based inspectors to examine activities as they

relate to inservice inspection (ISI) of piping system

components, steam generator sludge lancing, diesel generator

repair, and startup refueling testing.

One violation (Severity Level IV) was issued involving the use

of uncontrolled drawings by the Station Electrical Engineering

Department during the development of a modification to the

4160 volt ESF bus breaker interlocks. Another Severity Level

V violation was identified in this functional area concerning

physics testing and is discussed later in this section.

19

. ._ - ____-- -_ -___

.

. . . .

.

.

Another event involving modifications indicated the need to

provide better drawing detail to installers.

Outage planning is coordinated by a central outage planning

group under the direction of the Assistant Station

Superintendent, Outages. This individual is one of the most

experiented personnel at the station, having been in the

operating department since before initial criticality.

Outage schedules are developed using a computer program,

and schedules are updated weekly.

During the assessment period, station meeting routine was

changed to add a 7:00 a.m. morning meeting between repre-

sentatives of working groups to review and coordinate work

activities. The 8:15 a.m. morning management meeting format

was also changed to give greater detail on station work,

emphasizing each group's priorities of the day. In the

afternoon, another meeting is held to plan future work.

These meetings have been very beneficial to the flow of

information at the station.

Outage planning is done continuously using 6 month and 3 month

goals. The basic refueling sequence is " pre-set" in the

computer code and other jobs are added where they fit best

in the schedule. After an outage schedule is developed,

daily meetings described above are used as a means to

coordinate work and adjust the schedule as needed. Near

the end of the outage, lists are generated for certain key

milestones, such as drawing a pressurizer bubble. Onsite

reviews are performed prior to leaving cold shutdown.

Outage management for the July 1986, Unit 2 outage caused by a

lightning strike showed a very good approach to the resolution

of technical issues from a safety standpoint. During that

outage, a thorough review of instrumentation which could have

been affected by the lightning strike was conducted. Testing

to verify instrument operability was also conservative.

Management controls as indicated by outage related procedures

were generally adequate, although some deficiencies in

Maintenance Instructions (MI) and General Operating Procedures

(GOP) were identified. Minor ISI deficencies were also

identified in two LERs, and a defective hydrostatic test

procedure lead to the inoperability of the 18 auxiliary

feedwater pump in December 1985. Procedures for the outage

planning group have not been developed because corporate

guidelines have not been issued.

For the ISI areas examined, the inspectors determined that

the activities had received prior planning and priorities

had been assigned. Activities were controlled through the

use of well stated and defined procedures. Observation of

4

20

_ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ .

l'

.

.

ISI activities, sludge lancing, and repair welding indicate

that personnel have an adequate understanding of work

practices and that procedures were followed. Records were

found to be generally complete, well maintained, and available.

The records also indicate that equipment and material

certifications were current, complete, and that the personnel

performing nondestructive examinations and repair welding

were certified. Discussions with personnel performing

nondestructive examinations indicate that they were knowledge-

able in their work activities.

Refueling activities were performed without incident during

the assessment period. Refueling activities are performed by

a stable, well trained, group of fuel handlers. Replacement

of control rod guide tube, split pins, was also performed

without incident and ahead of schedule.

One inspection of core performance surveillance testing

following startup from a refueling outage was performed by.a

region-based inspector. The inspection included verification

that test results conformed with Technical Specifications and

procedure requirements and that any deficiencies identified

during the testing were properly reviewed and resolved. One

Severity Level V violation was identified concerning physics

testing at zero power, where testing was not performed in

accordance with written test procedures in that certain

4 procedure steps were not signed-off or performed before

proceeding to subsequent procedure steps. This violation had

minimal safety significance. However, similar problems in

'

controlling compliance to procedures and adequately reviewing

completed test results were documented in the SALP 5 assessment.

Although these problems had only minimal safety significance,

. the fact that they were repetitive indicates the need for

t

management attention to ensure that corrections prevent

recurrence.

During this assessment period, nuclear group staffing

adjustments were proposed and implemented; the resulting

level of staff in the nuclear group appears to be adequate.

2. Conclusion

The licensee is rated Category 1 in this are.. The licensee

was rated a Category 1 in Refueling during the last SALP

period.

3. Board Recommendations

None

21

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_

- _ - - - _ . _

,

_ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

I. Quality Programs and Administrative Controls Affecting Quality

1. Analysis

Examination of this functional area consisted of routine

inspections by the resident inspectors, and of one limited

scope inspection by a region based inspector. In addition,

an inspection of implementation of a program for preventing

overpressure transients was performed by a headquarters

inspector.

Two Severity Level IV violations were identified: (1) failure

to take adequate corrective actions following a loss of decay

heat removal event and (2) negative flux rate reactor trip

setpoints set incorrectly. This is a substantial improvement

from the previous assessment period when seven Severity Level

IV violations were identified.

An NRC headquarters inspection regarding overpressure

transients identified two incorrect assumptions in the

licensee's original calculations, however, the licensee

provided corrected data which demonstrated an adequate

design. The approach to resolution of technical issues

from a safety standpoint and responsiveness to NRC

initiatives was found satisfactory. The attitude and

system knowledge of the people encountered during the

inspection were excellent.

Sixteen out of 27 LERs which applied to this functional area

involved deficient procedures (14), lack of a procedure (1),

or drawings not showing sufficient detail (1). The licensee

has contracted for total rewriting of operating department

procedures (pts and GOPs) and has also contracted for

assistance in writing maintenance department procedures.

These actions should reduce the number of events due to

deficient procedures.

The station goals program is well developed, and effectively

run. General goals are formulated by management, and specific

goals are developed by working groups. Quarterly goals reviews

are conducted. Approximately 161 out of 215 goals were

achieved during the assessment period. Safety and regulatory

goals are included in the program.

l

'

At the beginning of the assessment period, Zion had been in a

Regulatory Perfcrmance Improvement Program (RPIP). Because

of improved performance, regular RPIP meetings with Region III

management were terminated on February 20, 1986.

Corrective action system documents, such as LERs and Deviation

Reports (DVRs), have improved during the assessment period.

In the past, root cause evaluations had occasionally lacked

detail, or had missed one or more contributors to events. ,

In addition, corrective act!ons to prevent recurrence were

22

____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

sometimes minimal or not addressed for one or more event

contributors. These concerns were expressed to licensee

management in October 1985. As part of an action plan to

improve LER/DVR quality, administrative procedures for LERs

and DVRs were revised and training was conducted for LER/DVR

writers and reviewers. LER/DVR quality has improved

substantially during the assessment period.

The site quality assurance (QA) department was well staffed by

qualified engineers and auditors. The group is effectively

managed, and has implemented several new audit methods. For

example, the group conducted a safety system functional

inspection of safety related portions of the CVCS system.

The inspection involved four auditors and was effective,

resulting in five findings and three observations. The site

QA group was also trained on aspects of fire protection which

they had not previously audited (fire barriers) and made several

findings of non-functional fire barriers (see section IV.E).

Management involvement in site quality assurrance has been

good. The licensee periodically reviewed the overall

effectiveness of the quality assurance program and assured

that personnel received timely training about changes made

to commitments in Technical Specifications, the QA Topical

Report, and the corporate QA manual. Response to NRC

-

identified issues in the area of Technical Specification

calibration testing was timely and thorough.

Management and corporate involvement needed improvement in

the area of Technical Specifications (TS) review and

implementation:

a. The negative flux rate reactor trip (NFRT) setpoints

were found to have been set nonconservatively for

several years,

b. Figure 3.2-9, the normalized Fq (Z) operating envelope

(K(2) curve) was found to be incorrect.

c. Changes to TSs were not properly translated into

procedures, which led to radiation monitor surveillances

being missed.

1

Items a and b involved old errors which the licensee had an

opportunity to detect and failed to do so, and c involved

inadequate review and implementation of a new TS. In the

past, changes to reactor containment fan coolers (RCFCs),

which made previously required surveillances both unnecessary

and impossible to perform were done without prior NRC approval.

10 CFR 50.59 states that prior NRC approval must be obtained

for plant changes which involve changes to the TS. In other

cases, TSs are difficult to interpret.

23

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_ _ _ _ _ _ _ _ _ _ _

.

.

2. Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rated of Category 2 in the last assessment period.

3. Board Recommendations

None

J. Licensing Activities

1. Analysis

During this assessment period, licensee management actively

participated in resolution of the various licensing issues

and kept abreast of current and anticipated licensing actions.

The submittal of only one request for emergency action during

the assessment period demonstrates foresight and advance

management attention to important safety issues.

The Regulatory Performance Improvement Program (RPIP)

additionally shows licensee management's dedication to

assuring safety. From the licensing perspective, this has

resulted in increasing pride in individual workmanship, and

increasing the desire for professional excellence.

Management involvement was particularly evident in closure of

several multiplant actions and attention given to important

issues. Licensee mid-management personnel frequently visited

the NRR Project Manager to inquire whether NRC licensing needs

were being met, both in substance and schedules.

The licensee maintained close control over licensing action

schedules and either met the originally established dates or

obtained timely acceptance of revisions.

The licensee demonstrated a thorough understanding and

appreciation of the technical issues involved and consistently

exhibited conservatism in analyses and proposed resolutions.

Rarely was there a need for requests for additional informa-

tion, and when such were sent, the response was timely and

technically sound. The licensee maintains a significant

technical capability in all the engineering and scientific

disciplines necessary to resolve items of concern to the NRC

and the licensee. In addition the licensee utilizes the

services of other nuclear support groups to assist in the

resolution of technical problems or to implement new and

proven techniques that will enhance the operation and safety

of the plant.

The completed multiplant actions listed in Section V.H.6

demonstrate the licensee's sound technical resolution of

24

_ _ _ _ _ _ _ __ _ _ __ ___

.

.

complex prom ems involving plant safety and plant operation,

with appropriate attention given to regulatory concerns.

The licensee was responsive to NRC initiatives in almost all

instances. Routinely, technically sound and workable

resolutions were proposed. Priority safety reviews and

responses were given prompt attention. The responses have

been thorough and sufficiently detailed to permit complete

review with little need for further interaction with the

licensee.

The licensee maintains open and effective communications

between NRC and its own licensing staffs. Almost daily

telephone contacts resulted in close cooperation between

licensee and NRR licensing personnel.

The licensee consistently has sent advance copies of submittals

by the overnight express service and, when urgent matters were

involved telecopied them to the Division of Licensing the same

day. Periodically, the Zion Licensing Administrator reported

on the progress of the various commitments to NRC.

To ensure even greater responsiveness to NRC initiatives, the

licensee has a dedicated, full-time coordinator to respond to

and track requirements from Generic Letters.

The licensee has been particularly responsive to NRC's requests

to assist or participate in special studies and surveys,

including visits to the station by NRC staff and contractors.

On such occasions, the licensee consistently made available

their most knowledgeable individuals to assist NRC visitors.

The corporate Zion licensing and engineering staffing is

ample and any vacancies were promptly filled with qualified

individuals. This resulted in no backlog of overdue licensing

actions and in prompt, timely processing of current actions.

The licensee maintains a competent licensing and engineering

staff to ensure technically sound and timely responses to NRC

requests. In addition to the engineering staff at the Zion

station, licensee maintains a Station Nuclear Engineering

Department in its corporate offices where a group of more

than ten engineers, dedicated exclusively to Zion, provides

engineering support to licensing activities and the station.

The corporate engineering support staff is expanding by the

addition of another department of Nuclear Fuel Services,

which is currently preparing to assume the responsibility

for performing the reload safety analysis for Zion Station.

The licensing staff consists of highly trained, qualified and

experienced individuals. For example, both the Zion Licensing

1

25

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, _ . . . . . _ . . . . .

i

.

.

! Administrator and the head of the Station Nuclear Engineerir.)

Department maintain current Senior Reactor Operator licenses.

Both individuals have spent several years at the Zion station

holding various responsible positions. The Licensing

Administrator, before his current assignment, headed the

training department at Zion station. In addition to

appointing highly trained individuals to the licensing

division, the licensee assures their continuing qualification

by providing additional training.

2. Conclusion

The licensee is rated Category 1 in this area. The licensee

received a rating of Category 1 in the last assessment period.

3. Board Recommendations

None

K. Training and Qualification Effectiveness

1. Analysis

Resident and regional inspectors have evaluated training and

qualification effectiveness during inspection of specific

program areas. In addition, an inspection was conducted to

evaluate the effectiveness of the licensee's licensed and

non-licensed personnel training programs. No violations were

identified.

During inspections of licensee activities, personnel were

found knowledgeable and effective in implementing their

duties. Training appeared to be well planned and adequately

presented. In cases where abnormal incidents had occurred

at the plant, the licensee prepared a Deviation Report (DR)

which was subsequently used to evaluate whether personnel

error contributed to the event. In cases where it did,

the licensee also evaluated the cause of the personnel error

including an assessment of whether the training program had

been effective or could have contributed to the cause of the

event. Of seven reactor trips in this assessment period,

three were related to personnel errors and possible training

deficiencies. In all cases, completed DRs were forwarded to

the Training Department for independent evaluation to determine

if the formal training program could be improved to prevent

recurrence of the incident. l

The licensee's formal training program for operations personnel

had been accredited by INP0. Instructors were required to

participate in the Company's Supervisor on Shif t (SOS) program.

There was a good feedback path between operations and training.

Operators were aware of the opportunities to provide suggestions

26

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.

.

for future modifications to the training programs. The

training department activities were guided by procedures that

implemented a well defined licensed operator program.

Inadequate training could only rarely be traced as a probable

cause of events occurring during this rating period.

The licensee's training program provided a means of

disseminating information related to operating deficiencies

and events to licensed operators. The Training Department

issued and controlled the required reading program and

incorporated lessons learned from past events into the

classroom training topics.

Required reading was distributed to all Zion licensed

individuals, non-licensed operators, radwaste foremen,

training staff, NRC operator license candidates, and

maintenance training coordinators.

Early in the assessment period, the NRC administered

replacement examinations to seven senior reactor operator

(SRO) candidates. Four passed and three failed. The three

who failed did so because they each failed the simulator

examination. These simulator failures could, in part be

attributed to the plant training department's unfamiliarity

with the new symptomatic emergency procedures which had

recently been introduced at Zion. Because these new emergency

procedures addressed more complex emergencies than the old

emergency procedures, the simulator scenarios used in the

examinations were required to be more complex as well. The

training department trained their candidates to handle

simulator scenarios which were adequate for the old emergency

procedures. The training department acknowledged that the

candidates should have been trained more thoroughly in complex

scenarios which the new emergency procedures are designed to

address.

The number of replacement examinations administered in the

period was too small to make any meaningful comparison with

the national pass rate average. It can be stated that all

candidates did pass an examination within the assessment

period.

Additionally, the NRC administered a requalification

examination to eight SR0's and four reactor operators (RO's)

in October 1986. Of the eight SRO's tested, seven passed

as well as the four R0's tested, resulting in a pass rate of

91.7%, which is above the national average.

The problem noted earlier concerning the inability of many

operators to properly use the new emergency procedures to

handle complex simulator scenarios was not evident during the

requalification exam, which indicates that this problem has

been properly corrected.

27

.

e

The facility has been cooperative with the NRC throughout the

assessment period, except for the licensee's initial reluctance

to supply' the Standing Orders to be used as exam reference

material.

For the maintenance groups, the training program was well

defined and implemented with dedicated resources. Inadequate

training could only rarely be traced as part of the cause of

events occurring during this rating period. The maintenance

on-the-job training (0JT) program was directed toward the

application of previously taught knowledge and skills to

maintain plant equipment. The Maintenance Training Program

will be used to ensure that mechanics who have not received

training or have not previously worked on a system will not

be assigned to jobs on that system unless they are accompanied

by a foreman or mechanic with training on the system. There

was a good feedback path from maintenance to the training

department, with pertinent items being factored into the

training program. Maintenance personnel were aware of their

opportunities to input suggestions for revisions to the

training program. The Training Coordinators understood their

training procedures and were implementing a well defined

maintenance training program.

The licensee has begun a two-week radiation / chemistry

technician annual requalification training program involving

the use of new instrumer,ts as well as discussion on health

physics topics. In addition, the chemistry staff has received

a pilot training program on water chemistry control, in

response to a corporate directive on this subject, to alert

personnel of the significance of maintaining good water

chemistry for long-term plant reliability.

Seven training programs (Shift Technical Advisor, Instrument

Maintenance, Electrical Maintenance, Mechanical Maintenance,

Radiation Protection, Chemistry, and Technical) have been

submitted to INPO for accreditation. Full accreditation is

expected by the Fall of 1987.

In cases where the NRC recommended improvements to the training

program, the licensee was very responsive in addressing the NRC

concerns.

2. Conclusion

The licensee is rated Category 1 in this area. This area was

not rated in the last assessment oeriod, because this is a new

functional area.

3. Board Recommendations

. None

28

l

- - _ _ - . _ . - - . . - - - - . _ _ _ _ _ - _ - _ - - ._ _. . - ___

.

.

o

V. SUPPORTING DATA AND SUMMARIES

A. Licensee Activities

1. Unit 1

Zion Unit 1, began the assessment period in routine power

operation and ended the assessment period in a refueling

outage. This refueling outage is expected to last until

March 3, 1987 (SALP 7). During this assessment period,

Unit 1 experienced two outages.

Unit 1 outages are summarized below:

a. March 10-17, 1986: After receiving a full power reactor

trip, due to a reactor trip breaker not being properly

racked into place, Unit I remained shutdown to repair a

bowed shaft on a RHR pump,

b. September 4, 1986: Unit 1 began it's 17 week, routine

refueling and maintenance outage.

2. Unit 2

During this assessment period, Unit 2 began the assessment

period in an extended refueling outage; this refueling outage

lasted until February 4,1986. Unit 2 experienced seven

outages.

Unit 2 outages are summarized below:

a. December 6, 1985 thru February 4, 1986: Shutdown for

refueling, routine maintenance and 10 year in-service

inspections.

b. February 28 thru March 2, 1986: Unit 2 was taken off

line to perform over-speed trip vibration tests on the

newly installed Brown-Boveri low pressure steam turbine.

c. March 24 thru 25, 1986: After receiving a trip from

full power during reactor protection system testing,

Unit 2 remained shutdown to investigate electrical noise

and radio frequency problems in the nuclear instrumenta-

tion drawers,

d. June 27 thru July 14, 1986: Unit 2 remained shutdown

due to failure of primary system instruments after a

lightning strike caused a reactor trip on high Over-

Temperature Delta-T. Five reactor coolant system

resistance temperature detectors were replaced, one

accumulator transmitter was recalibrated, and maintenance

was performed on an essential service water pump.

29

Mc

'

s, ' ' \

t e

,

, ,

I  %,yg -t , s

7 .

'

- t A i  ; s. ._

e

f

'

e, '1986: Unit 2 was shutdo*, from mode 2 (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> -

yJuly

LCO act 5,'f an staAament) to repair esstotial service water

a

pumon %ich we're out of servicel ei t

, sc ,

, q f. September 20-22, 1986: Unit 2 was shutdown to repair , .

.

the turbine electro-b3draulic control system. N

N ( " '

..

T B. Inspection Aci.iv'1 ties

p. , (- 'Q,y v. -

There were 33) inspections concucted at Unit 1 and 33 inspections '

o

conducted at'# nit 2 during this, assessment period for October 1,

1985 througti Xavember 30,1986.*? ,

'

'

1. Inspe::tf on Data

Facility Name: Zion '

'3

Unit: 'l ,

Docet No . : 50-295 *

e, i

" Ins'p'edtion Reports No. : 85001, 85032, 85036, 85038 through

'

85043, 86001 through 86019, 86021 t t. cough

j~86024, 86027 and 86029.86005,l86007/through

'

t ', . >

's t,,

'

Facility Name: Zion ,

Unit: 2 c'y

Docket No.: 50-304 -

3

s ',

, Inspection Reports No.: 85001, 85033, 85035, 85038 through , e

85044, 86001 through 86005, 86007 through 26019, 86020,  ;, -

86022 through 86024, 86027,'and 86029. j

'

'

Table'1

'

, \. [s

'

e

,

,  ; ,s

Number of Violations in Each Severity Level

'

. .. 1- Commontd

i Unit 1 , Unit 2 Both Units

Functional Areas o I II III IV V I II III IV V I II III IV V

r

A. Plant Operations 3 1 1

B. Radiological Controls 1  %

C. Maintenance 2

D. Surveillance . 2

E. Fire Protection 1

F. Emergency Preparedness '

G. Security 1'

H. Outages 11

1. Quality Programs and

Adminis. Controls

Affecting Quality 2

J. Licensing Activities '

,

,

K. Training & Qualification

Effectiveness

t.

TOTAL I II III IV V

0 0 0 30

I II III IV V

0 0 0 31 I II III N

0 0 \0 90

t V'

30

s

s

_ _ _ _ _ _ _ _ - - _

-_- - _ - _ _ - _ _ - _ _ _ - _ _ _ -

'

,

4 - , .s <

., 3

l l 2. Special Inspection Summary

. s

4 None

i

C. Investigations and Allegations Review

'> Allegation Review

Seven allegations relating to Zion consisting of eleven concerns

were received in Region III during this assessment period. Four

allegations were of a nature that they were closed following

regional review. Two others dealt with safeguards issues and one

, No safety significance issues

y, l } pertained

or violationsto administrative

were identifiedissues.

from the NRC review of these

,'

/

'

,

'

g allegations.

c 1

-

D. {scalatedEnforcementActions

No civil penalties were issued during this assessment period.

Y During this assessment period one Severity Level III violation,

,

regarding the inoperable IB auxiliary feed water pump, was

initially proposed with a $25,000 civil penalty. However, after

the NRC reevaluated the licensee's response, the severity level

yas reduced to Severity Level IV based on the over 100% of

required capacity remaining even with the one pump inoperable.

E. Licensee Conferences Held During Assessment Period

1. January 10, 1986, (Regional Office) - Management meeting to

discuss the findings of Zion's SALP 5.

'

2. March 14, 1986 (Regional Office) - Enforcement Conference was

held to discuss information regarding the IB auxiliary feed

water pump which were inoperable due to having service water

to the bearing oil cooler valved out.

3. April 9, 1986, (SITE) - A tour and management meeting with

representatives from Zion plant management to discuss

operational safety.

4. April 29, 1987, - Management meeting regarding the history

behind improperly set negative flux rate reactor trip (NFRT)

setpoints, and to discuss corrective actions taken in response

to the December 14, 1985, loss of residual heat removal event

which occurred when Unit 2 was in cold shutdown.

(

5. May 21,1986, (Site) - Management meeting to tour the facility

and meet with station management.

F. Confirmation of Action Letters

October 27, 1986, A Confirmatory Action Letter was issued following

the October 24, 1986, failure of the IB diesel generator during

post-maintenance testing.

31

'

_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - - _ _ _ _ _

~

,y,q '

'

,

, (

/- ,tt e

' . ,

G. A Review of Licensee Event Reports and 10 CFR 21 Reports Submf tted

by-the Licensee

1. Licensee Event Reports (LERs)

1

'

Unit 1

,. Docket No.: 50-295

4 LERs Nos.: 85040, 85042 thru 85047, and 86001 thru 86040.

i Unit 2

l Docket No.: 50-304

l LERs Nos.: 85026 th;*u 85029 and 86001 thru 86022.

Seventy-three LERs were issued during this assessment period;

30 LERs were the result of personnel errors; 22 LERs resulted

from procedure inadequacies; 7 LERs were due to component /

equipment failures; 4 LERs were related to design problems;

and 10 LERs fell into the other categories (i.e., unknown

human errors, external causes, and other).

1

CAUSE Unit 1 Unit 2

Personnel Errors '

18 12

Procedure Inadequacies 15 7

, Design / Construction 2 2

External Causes 0 1

Component / Equipment 6 1

Other 5 2

Unknown Human Errors 1 1

NOTE: The above information was derived from reviews of

Licensee Event Reports performed by NRC Staff and

may not completely coincide with the unit or cause

assignments which the licensee would make. In

addition, this table is based on assigning one cause

code for each LER and does not necessarily correspond

to the identification of LERs addressed in the

Performance Analysis Section (Section IV) where

multiple cause codes may be assigned to each LER.

The frequency of occurrence of LERs was unchanged since the

previous SALP. During SALP 5 95 LERs were identified over a

17 month assessment period or an average of 5.3 per month

compared to an average of 5.2 LERs per month during this

assessment period. The percentage of LERs which were caused

by personnel error increased during this assessment period

from 32.7% to 41.1%. Although this percentage is not

considered excessively high, the number of LERs issued is

high and improvements in both statistic is warranted.

32

- - - - - - - - - - - - - )

o

~

o

l 2. Analysis and Evaluation of Operational Data (AE00)

'

The results of the AE00 evaluation of Zion Licensee Event

Reports for this assessment period indicated an improvement

in both content and quality. AEOD assessed an average score

of 8.8 out of a possible 10 points; compared to Zion's

previous overall average score of 6.8 and the current reactor

industry average of 8.1. AE00 indicated that information

concerning the identification of failed components needs to

improve. However, strong points of the Zion LERs are that

information concerning mode, mechanisms, and effect of a

failed components is well written.

2. 10 CFR 21 Reports

(a) Inspection Report 304/85018 documented limitorque wires

for which there was inadequate environmental qualification

documentation.

(b) Inspection Report 304/86017 documented leaking Anderson-

Greenwood 5-valve manifolds.

H. Licensing Activities

1. NRR Site Visits / Meetings / Licensee Management Conferences

Inadequate Core Cooling January 21, 1986

Core Reload Methodology January 31, 1986

Appendix R, Fire Protection September 30, 1986

Pressurized Thermal Shock October 3, 1986

Site Visit May 12-16, 1986

2. Commission Meetings

None

3. Schedule Extensions Granted

None

4. Reliefs Granted

ASME Code, Rev. 5 to ISI Program March 27, 1986

5. Exemptions Granted

None I

6. Licensee Amendments Issued

Amendment

Number Title Date

33

__ _

c>

%

4

91/81 Items A.1 and A.2 of 1980

Confirmatory Order December 31, 1985

92/82 Capsule withdrawal schedule January 16, 1986

93/83- Mechanical and hydraulic snubbers January 22, 1986

94/84 Enrichment limits for new and

spent fuel pools February 19, 1986

95/85 Negative rate trip setpoints March 10, 1986

96/86 Radiological Environmental

Technical Specifications March 24, 1986

97/87- Degraded grid voltage protection

system March 27, 1986

98/88 S.G. tube sleeving methodology November 18, 1986

7. Emergency Technical Specifications Issued

Amendments 95 and 85 - Negative rate trip setpoints - issued

March 10, 1986,

8. Orders Issued

None

9. NRR/ Licensee Management Conference

None

.

34